BIR Ruling No. 435-61

December 8, 1961 BIR RULING NO. 435-61 In response to the request contained in your letter . . . , I regret to have to inform you that existing policy of this Office prohibits release to third persons of copies of rulings for the reason that it may contravene the provisions of Section 347 of the National Internal Revenue Code. However, this Office has ruled that registered nurses employed in private hospitals, irrespective of the amount of salary they receive and regardless of the fact that they are mere employees who do not go out in the field to practice their profession, are subject to the occupation tax prescribed in Section 182(B) of the same Code, unless the hospital is not conducted for private gain. Company hospitals do not come within the purview of the term "not conducted for private gain". cdasia